Government has an opportunity to learn lessons from its experience of implementing cross-border travel measures during the COVID-19 pandemic should such measures be needed in the future, according to a report by the National Audit Office (NAO).

Putting cross-border travel measures in place, often at speed, and adapting and sustaining them, has required the considerable efforts of government and others to deliver the changes to time-pressured deadlines.

Between February 2021 and January 2022, the rules for the border were changed at least 10 times. Although individual departments have had their own governance structures for managing the programmes they are responsible for, government did not have an assessment bringing together all the risks across its border measures for the system as a whole. Good practice, such as system-level risk registers, has not been adopted, which would have helped the government to learn lessons and better adapt its approach.

The government has had to balance decision-making on public health with other competing objectives, such as reopening international travel safely, mitigating the risk of variants of concern, and minimising disruption at the border. The balance between these objectives fluctuated to adapt to the changing nature of the pandemic. However, the government has not stated how these competing objectives should be balanced and prioritised.

A digital Passenger Locator Form1 (PLF) for passengers arriving into the UK was introduced by the Home Office quickly and went live as planned in June 2020. Even with the checks imposed, some information submitted on PLFs may not have been accurate as checks by private sector carriers focused on the existence rather than the accuracy of data. From February 2021, until the PLF was withdrawn in March 2022, private sector carriers had to check that everyone travelling to the UK had submitted a PLF. The percentage of checks undertaken by Border Force has reduced over time and since September 2021 less than 1% of people arriving have had their PLF checked. The Home Office considered that Border Force checks were statistically robust and that those, combined with the automatic verification of key data fields built into the PLF, enabled it to have confidence in the high rate of compliance found by carriers, which it estimated at up to 99%.

From January 2021 to February 2022, most people had to pay for COVID-19 tests taken after arriving in the UK. The Department of Health and Social Care (DHSC) set out to create a market for COVID-19 testing so as to protect domestic testing capacity. Government had limited oversight of the market it created, and service to the public has sometimes been poor. On 15 February 2022, at least 369 private firms offering PCR tests were listed on, with their stated prices ranging from £15 to £525. Firms listed on have often marketed themselves as being government approved, but DHSC’s listing process gave minimal assurance that they can provide the services. In September 2021, the Competition and Markets Authority (CMA) recommended government take action to give consumers information on provider quality. Despite complaints of providers failing to deliver tests or results, DHSC has yet to formally respond to the CMA recommendations.

When people were required to self-isolate after travel2, the UK Health Security Agency (UKHSA)3 attempted to contact people meant to be self-isolating by phone call and text message, supplemented by a £114 million contract for home visits. Between May 2021 and February 2022, UKHSA was unable to confirm whether on average one third (33%) of those required to isolate had been doing so, ranging between 26% and 42% of possible non-compliance during these months. This was above the 25% non-compliance it expected.

DHSC moved rapidly to set up the Managed Quarantine Service (MQS), which it launched on 15 February 2021. The MQS handled 214,000 arrivals between April and December 2021 from red list countries, who were required to isolate for 11 nights in a quarantine hotel provided by the service. An estimated further 14,000 arrivals were able to claim exemptions from hotel quarantine. Most people with exemptions were subject to alternative COVID-19 health measures.

DHSC had originally thought the cost of running the MQS service would be met by the price charged for the quarantine hotel rooms, but in the event the taxpayer has subsidised half of its total £786 million cost. DHSC has not been able to determine how many COVID-19 cases were prevented by the MQS, but between 15 February and mid-December 2021 some 2% of quarantined guests tested positive for COVID-19. From 9 to 15 December 2021, during the Omicron outbreak, 6% of all tests taken from guests were positive.

Although individual departments have been monitoring their own spending on implementing cross-border travel measures in response to COVID-19, government has not routinely tracked the total cost across government despite spending at least £486 million4. Government told the NAO that cost had not been a factor in its implementation decisions. Without a set of performance measures to track effectiveness and with no evaluation of the additional costs incurred, government cannot demonstrate that its implementation measures have achieved value for money.

To inform government’s future approach and strategy for what follows, departments should establish a clear system-level risk management framework to support government decision-making, setting out who is responsible for capturing and managing the risks. Should measures be needed again, government should have key metrics to judge the effectiveness of the overall system, to understand performance and inform future decisions.

“The government has had to balance many competing objectives when managing the border through the pandemic, making changes at short notice to adapt to the challenges of COVID-19. After two years of the pandemic and following the recent removal of travel restrictions, the government has an opportunity to ensure that it develops a systematic approach to managing any future travel measures, applying the learning from COVID-19.”

Gareth Davies, the head of the NAO

Read the full report

Managing cross-border travel during the COVID-19 pandemic

Notes for editors

  1. Passenger Locator Forms record contact information, recent travel history, vaccine status and compliance with COVID-19 measures for passengers arriving in the UK.
  2. The traffic light system that required people arriving from amber list countries to self-isolate was in operation from May 2021. By 15 December government had removed all remaining countries from the UK travel red list, and on 11 February 2022, all testing requirements were removed for fully vaccinated arrivals, effectively standing down the traffic light system. On 18 March 2022, the remaining COVID-19 travel measures were removed.
  3. The DHSC arm’s-length body that, from 1 October 2021, has been responsible for planning, preventing, and responding to external health threats.
  4. The NAO identified some specific costs of the components of the overall system, using government estimates of its spending, amounting to at least £486 million in 2021-22.
  5. Press notices and reports are available from the date of publication on the NAO website. Hard copies can be obtained by using the relevant links on our website.


About the NAO

The National Audit Office (NAO) scrutinises public spending for Parliament and is independent of government and the civil service. It helps Parliament hold government to account and it uses its insights to help people who manage and govern public bodies improve public services.

The Comptroller and Auditor General (C&AG), Gareth Davies, is an Officer of the House of Commons and leads the NAO. The NAO audits the financial accounts of departments and other public bodies. It also examines and reports on the value for money of how public money has been spent.

In 2020, the NAO’s work led to a positive financial impact through reduced costs, improved service delivery, or other benefits to citizens, of £926 million.

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